ML20214K740

Forwards Phillips 800721 Memo to Seidle Re Investigation Rept 79-19 Re Lessons Learned

ML20214K740
Person / Time
Site:	South Texas
Issue date:	08/13/1980
From:	Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20214K710	List: ML20214K709 ML20214K740
References
FOIA-85-378 NUDOCS 8612020442
Download: ML20214K740 (1)

Text

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'c, NUCLEAR REGULATORY COMMISSION REGION IV P -' - e 611 RY AN PLAZA DRIVE.5UITE 1000

',j ARLINGTON. TEXAS 76012

\l' .. . ff August 13, 1980 4

Mfghf MEMORANDUM FOR: K. V. Seyfrit, Director FROM: W. C. Seidle, Chief, RC&ES Branch

SUBJECT:

SOUTH TEXAS PROJECT INVESTIGATION 79-19 LESSONS LEARNED: MEMORANDUM, PHILLIPS TO SEIDLE, DATED JULY 21, 1980 A copy of the subject memorandum is forwarded to you for consideration, f/ /%dA WN. Seidl'e, Chief Reactor Co'struction and Engineering Support Branch cc: W. A. Crossman H. S. Phillips 8612O20442 861120 PDR FOIA GARDE 85-378 PDR m

... *l ^ bVu GOVERNMENT ACCOUNTABILITY PROJECT 1555 Connecticut Avenue, NW., Suite 202 Washington, D.C. 20036 (202)232-8550 May 16, 1985 EBEEDOM OF INFORMATON w..

FREEDOM OF INFORMATION ACT REQUEST FoI A-05-378 Director M M Office of Administration Nuclear Regulatory Commission Washington, D.C. 20555 To Whom It May Concern:

Pursuant to the Freedom of Information Act ("FOIA"), 5 U.S.C. 6552, the Government Accountability Project ( "G A P" )

requests copies of any and all agency records and information, including but not limited to notes, letters, memoranda, drafts, minutes, diaries, logs, calendars, tapes, transcripts, summaries, interview reports, procedures, instructions, engineering analyses, drawings, files, graphs, charts, maps, photographs, agreements, handwritten notes, studies, data sheets, notebook s, books, telephone messages, computations, voice recordings, computer runoffs, any other data compilations, interim and/or final reports, status reports, and any and all other records relevant to and/or generated in connection with the information regarding copies of the depositions of all NRC personnel deposed in the litigation between Houston Light and Power Company and Brown and Root, Inc. over the South Texas Project.

This request includes all agency records as defined in 10 C.F.h. 99.3a(b) and the NRC Manual, Appendix 0211, Parts 1.A.2 and A.3 (approved October 8, 1980) whether they currently exist in the NRC official, " working", investigative or other files, or at any other location, including private residences.

If any records as defined in 10 C.F.R. i9.3a(b) and the NRC Manual, supra, and covered by this request have been destroyed and/or removed after this request, please provide all surrounding records, including but not limited to a list of all records which have been or are destroyed and/or removed, a description of the action (s) taken relevant to, generated in connection with, and/or issued in order to implement the action (s).

h e.

) GAP requests that fees be waived, because " finding the information can be considered as primarily benefitting the general public," 5 U.S.C. }552(a)(4)(a). GAP is a non-profit, non-partisan public interest organization concerned with honest and open government. Through public outreach, the Project promotes whistleblowers as agents of government accountability.

Through its Citizens Clinic, GAP offers assistance to local public interest and citizens groups seeking to ensure the health and safety of their communities. The Citizens Clinic is currently assisting several citizens groups, local governments and intervenors in the central Texas area concerning the construction of the Comanche Peak nuclear power plant.

We are requesting the above information as part of an ongoing monitoring project on the adequacy of Region IV and the NRC's efforts to protect public safety and health at nuclear power plants.

For any documents or portions that you deny due to a specific FOIA exemption, please provide an index itemizing and describing the documents or portions of documents withheld. The index should provide a detailed justification of your grounds for claiming each exemption, explaining why each exemption is relevant to the document or portion of the document withheld.

This index is required under Vaughn v. Rosen (I), 484 F.2d 820 (D.C. Cir.197 3 ), cert. denied, 415 U.S. 977 (1974).

We look forward to your response to this request within ten days.

Sincerely, LNbh Billie Pirner Garde Director, Citizens Clinic o

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UNITED STATES NUCLEAR REGULATORY COMMISSION Y

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Docke o. 50-498/Rpt. 77-08 Houston Lighting and Power Company -

ATTN: Mr. G. W. Oprea, Jr.

Executive Vice President Post Office Box 1700 Houston, Texas 77001 Gentlemen:

This refers to the investigation conducted by Messrs. J. E. Foster and R. G. Taylor of our staff during the period July 6-8, 1977, of activities authorized by NRC Construction Permit No. CPPR-128 for the South Texas Project facility, Unit No.1 and to the dis-cussion of our findings held with Mr. R. A. Frazar and other members of your staff ,at the conclusion of the investigation.

Areas examined during the investigation and our findings are dis- '

cussed in the enclosed investigation report. Within these areas, the investigation consisted of selective examination of procedures and representative records, interviews with personnel, and observations by the inspectors. .

Within the scope of the investigation, no items of noncompliance were identified. '

In accordance with Section 2.790 of the NRC's " Rules of Practice,"

Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed investigation report will be placed in the NRC's Public Document Room. If the report contains any information that you believe to be proprietary, it is necessary that you subunit a written application to this office, within 20 days of the date of this letter, requesting that such information be withheld from public disclosure. The application must include a full statement of the reasons why it is claimed that the information is proprietary. The 5

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O A Houston L.ighting and Power Company August 2.1977 application should be prepared so that any proprietary information identified is contained in an enclosure to the application, since ..

' the application without the enclosure will also be placed in the Public Document Room. If we'do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room.

Should you have any questions concerning this investigation, we -I 4 will be pleased to discuss them with you. '

sincerely, d b 4

W. C. Seidlh, Chief Reactor Construction and Engineering Support Branch

Enclosure:

IE Investigation Report No. 50-498/77-08 i

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e U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMEtlT REGION IV REPORT OF INVESTIGATION Report No. 50-498/77-08 Docket No. 50-498 Category A2 Licensee: Houston Lighting and Power Company Post Office Box 1700 Houston, Texas 77001 Facility Name: South Texas Project, Unit No.1 Investigation at: Bay City, Texas Investigation conducted: July 6-8,1977 Investigators: /7, / / f/ 9 E. Foster,fnvestigative Specialist (RIII) Date W 2b' 'k'7 R. G. Taylor,fe, actor Inspector Dater Reviewed:

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h7 W. C. Seidle," Chief, Reactor Construction and Date Engineering Branch Investigation Surrary:

Investigation on July 6-8, 1977 (Report No. 50-498/77-08)

Areas Inspected: Special announced investigation into concrete placement quality control; interviews with quality control inspectors; review of quality control procedures and organization; discussions with management personnel. The investigation involved twenty-eight inspector-hours on l site by two NRC inspectors. }

Resul ts : No items of noncompliance or deviations were identified.

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IflTRODUCTI0ff Brown and Root, Inc. , (B&R) is the Architect-Engineering firm and Constructor for the South Texas Project fluclear Power Station, licensed to the Houston Lighting and Powe_r Company (HL&P). As a part of the B&R quality control program, B&R.provides quality control inspectors to monitor the site construction activities. B&R Civil quality control inspectors monitor various phases of the construction process, including reinforcement bar placement, concrete form manu-facture, and concrete placement.

REAS0ff FOR It1VESTIGATION Following receipt of a telephone call on July 1,1977, during which it was alleged that quality control inspectors at the South Texas Project site were being threatened with beatings if they identified any unacceptable items during concrete placement inspections, RIV initiated an investigation into the allegation.

SUMMARY

OF FACTS On July 1,1977, an individual who identified himself as Individual "A" contacted RIV Inspector R. Taylor by telephone. Individual "A" indicated that an incident had taken place at the South Texas Project (STP) in which a B&R Construction foreman had assaulted and injured a B&R Civil Quality Control (QC) inspector, and alleged that the incident was just one of a series of threats and harassments against B&R QC inspectors. Individual "A" also alleged that a B&R Construction Superintendent had advised his workers that any B&R Civil QC inspector who reported unacceptable items found during concrete placement inspections would be liable for a beating.

RIV contacted B&R and substantiated that an altercation had taken place between a B&R Civil QC inspector and a B&R Construction foreman at STP. B&R was advised of the general nature of the allegations made to RIV, and that an investigation would be initiated into the matter.

During July 6-8, 1977, a RIII Investigator and a RIV Inspector visited STP and interviewed all present B&R Civil QC inspectors, including the QC inspector involved in the altercation with the B&R Construction '

foreman, interviewed B&R Construction personnel, reviewed the structure and procedures for the B&R QC function, and held discussions with HL&P personnel.

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,A A Interviews with B&R Civil QC personnel indicated that an inordinate amount of friction had developed between the B&R Civil QC inspectors and the B&R Construction personnel involved in concrete placement. l It was also indicated that various minor harassments, such as offend-ing commends on the site radio channels, had sometimes been directed toward the B&R Civil QC inspectors.

Statements received during the interviews with B&R Civil QC inspectors appear to indicate that the allegation made to RIV relates to two incidents which took place on June 30, 1977. On the morning of that date, Individual "F" a B&R Civil QC inspector and Individual "M" a B&R Construction foreman, had a heated verbal argument over a concrete QC inspection, and threatening statements were apparently made by both parties. Both individuals, when interviewed, stated that any threaten-ing statements made during the argument were made in the heat of the argument, and were regretted.

On the afternoon of June 30, 1977, a B&R Civil QC inspector was involved in an altercation with a B&R Construction foreman. Individual "B", the B&R QC inspector involved in the incident, stated that the altercation was totally unexpected, and not a part of any long-term friction between him and Individual "C", the Construction foreman involved. Individual "B" indicated that the incident may have been partially accidental in that Individual "C" may not have intended that Individual "B" fall and injure himself.

Individual "B" stated that he was threatened by an unknown laborer as he left the plant site af ter the incident. There was no evidence that this threat was a part of a program of harassment of intimid-ation of B&R QC inspectors. The laborer may have made the threat to show sympathy with Individual "C" (as the threat was made immedi-ately af ter the incident).

The individual who made the telephonic allegation to RIV and identi-fied himself as Individual "A" could not be located. flone of the personnel employed at the STP site were so named, and Individual "A" did not identify himself to flRC representatives during this investi-gation. Individual "C" was not interviewed, as he had terminated his employment at the site, and was unavailable for interview.

The two incidents did not provide sufficient evidence to substantiate the allegation that there was a directed program of harassment and intimidation of B&R QC inspectors. flo evidence was developed that the B&R Construction Superintendent had advised his workers that any B&R QC inspector who found and reported unacceptable items during concrete placement inspections would be liable for a beating.

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DETAILS.

Personnel Contacted i .

l Houston Lighting and Power Company i

• R. A. Frazar, Quality Assurance Manager .

• W. N. 'Phillips, Project Quality Assurance Manager .

• F. D. Asbeck, Construction Supervisor

• L. D. Wilson, Lead Specialist .

*T. K. Logan, Lead Engineer .

Brown and Root, Inc. , (B&R)

C. Crane, Construction Project Manager 3

• J. Monroe, Assistant Construction Manager t

J. Salyitti, General Superintendent Civil Construction Q. Lindsay, Quality Assurance Manager i *M. T. Meyer, Houston Coordinator

• T. P. Gardiner, Project Quality Assurance Manager T. Schreader, Quality Control Supervisor 4

i Individuals l Individuals "A" through "M" ll i

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• Attended close-out meeting.

Scope l- .

i This investigation focused on the Civil Construction quality control 5

program conducted by Brown and Root, Inc., at the South Texas Project Reactor construction site. The allegations received related to civil

, construction quality control inspectors only, and other phases of B&R quality control were not inspected. Emphasis was placed on the question of whether B&R QC inspectors were being threatened and intimidated to

overlook unacceptable conditions during their inspections.

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[ On July 7,1977, employee lists were reviewed, interviews were held i with all present B&R Civil QC inspectors, the B&R QC organizational -

structure was reviewed, B&R Construction management personnel were j interviewed and discussions were held with HL&P personnel. -

i On July 8,1977, discussions were held'with HL&P personnel and inter-views were held with B&R QC inspectors. An investigation close-out

! meeting was held on this date.

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Interviews with B&R Civil Quality Control Inspectors On July 7,1977, all present B&R Civil QC inspectors involved in i

concrete inspections, a total of ten inspectors, were interviewed by the tiRC representatives. ,

, Four of the inspectors interviewed indicated that they had not experienced any problems or harassment from construction workers.

The four inspectors who indicated no problems were noted to be either trainees or to be assigned to inspections of non-safety areas of the plant where inspection criteria are less strict than those for safety-related areas.

The other Civil QC inspectors indicated that they normally have very few problems with their inspections, but that they had experienced some harassment before and during periods when concrete pours were in progress. In general, the inspectors comments reflected minor harassments, such as comments from the workers, radio transmissions critical of the QC inspectors, and verbal arguments with the B&R Construction foremen involved with concrete placement. Several inspectors stated that whenever a problem occurred in connection with a concrete pour, the Construction foreman in charge of concrete placement would step in, even if the inspection problem involved another craft such as ironworkers.

Several inspectors indicated that they thought that B&R QC was not getting enough managerial support, and stated that when a dispute arose between them and a Construction foreman, the B&R General Superintendent for Construction would often enter the dispute and argue with them.

Several QC inspectors commented that the QC inspector turnover had been high, due to low morale among the QC inspectors and other factors. The inspectors stated that none of the QC inspectors who had left the job site had claimed that they did so because they had been threatened, harassed, or intimidated on the job.

Each Civil QC inspector was questioned as to whether any inspector had overlooked any unacceptable inspection items as a result of harassment on the job. All of the inspectors indicated that they had not overlooked unacceptable inspection items, and several inspec-tors commented that they had become more strict in their inspections because of the friction between them and the Construction Branch.

Interview with Individual "F" Individual "F" was interviewed on July 7,1977. He indicated that he had been the object of some of the minor harassments previously mentioned.

,- e a Individual "F" stated that on the morning of June 30,1977, he had performed an inspection just prior to a planned concrete placement

-pour, and had found what he considered to be an unacceptable item whose correction had delayed the concrete pour. He stated that he and the Construction foreman, Individual "M", became engaged in a -

heated verbal argument as a result of his action, and that during

, the argument Individual "M" had threatened him with a beating.

l Individual "F" indicated that Individual "M" had taken no action to follow up on the threat.

Interview with Individual "B" Individual "B" was interviewed on July 7, 1977. Individual "B" stated that he had been involved in an altercation with a Construc-tion foreman on the afternoon of June 30, 1977.

Individual "B" said that he was involved in an inspection at approxi-mately 4:00 p.m., on that date and that he had requested Individual "C", the Construction foreman for that particular work crew, to have a slick line removed from the area of his inspection. Individual

'"C" apparently took offense at this, Individual "B" stated, for he turned to Individual "B", they exchanged words, and Individual "C" took hold of Individual "B"'s collar and shook him. Individual "B" indicated that they had both been standing on concrete reinforcement bars, and that as a result of being shaken by Individual "C", he lost his balahce and fell with Individual "C" on top of him.

i Individual "B" stated that he had not had any previous problems with Individual "C", or with any other Construction foremen, and that the incident had taken him totally by surprise. He indicated that Individual "C" may not have intended that he lose his footing and fall.

Individual "B" stated that an unknown worker had threatened to kill him (no other comment), and that this threat took place as he was leaving the plant site immediately after the incident described above. Individual "B" indicated that this was the first time that he had been threatened, and that no subsequent threats had been made.

Interview with Individual "M" -

Individual "M" was interviewed on July 7, 1977. Individual "M" stated that he was the B&R Construction foreman who had been in-volved in a heated argument with Individual "F" on June 30, 1977, and that he had threatened Individual "F" with a beating during the argument. Individual "M" indicated that Individual "F" had also made threatening statements during the argument. .'

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Individual "M" stated that the threats that he had made were made during the heat of the argument, and that upon gaining his com-posure, he regretted making the statements.

Discussions with B&R Construction Management Personnel .

Discussions with B&R Construction management personnel indicated that the period just prior to, and during, a concrete placement pour 4

is a crucial period when there is considerable pressure to complete

! the pour as scheduled. This is because advance plans for personnel and material have to be made before the pour is performed, and/any delay in the pour, once scheduled, is costly. Therefore, QC inspec-tions made during this period receive increased attention from the personnel involved in concrete placement.

The B&R General Superintendent for Civil Construction indicated that

• the B&R Concrete General Superintendent is responsible for seeing that any QC inspection problems are rectified and that concrete placement is accomplished on schedule, and that, therefore, he would

. become involved in any inspection problem which could delay a concrete

' pour. This would account for the QC inspectors' perception that concrete placement personnel step into any inspection problem even if the problem relates to another craft. ,

It was indicated that B&R Construction management personnel had been

, aware that friction had been building between the Civil QC inspectors and the Construction foremen and personnel involved in concrete placement, and that a meeting had been scheduled to discuss the problem prior to the altercation between the QC inspector and Construction foreman. This meeting was postponed due to the events

, on June 30, 1977.

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j In Reply Refer To:

RIV Docket Nos. 50-496/78-12

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{ 50-499/78-12 Houston Lighting and Power Company i ATTN: Mr. E. A. Turner, Vice President Power Plant Construction and ~

I Technical Services Post Offica Box 1700 Houston, Texas 77001 Gentlemen:

This refers to the investigation conducted by Mr. J. J. Ward and other

members of our staff during the period July 25-28, 1978, of activities l authorized by NRC Construction Pemit Mos. CPPR-128 and 129 for the 1 South Texas Project facility, Units No. I and 2, concerning an allegation

by a Brown and Root employee.

! The investigation and our findings are discussed in the enclosed investi-l gation report.

l Within the scope of the investigation, no itses of noncompliance were

identified.

! In accordance with Section 2.790 of the NRC's " Rules of Practice " Part i 2, Title 10, Code of Federal Regulations, a copy of this letter and the

! enclosed investigation report will be placed in the NRC's Public Document

, i' Room. If the report contains any infomation that you believe to be

proprietary, it is necessary that you submit a written application to l l this office, within 20 days of the date of this letter, requesting that l such information be withheld from public disclosure. The application i

must include a full statement of the reasons why it is claimed that the

infomation is proprietary. The application should be prepared so that i t any proprietary infonation identified is contained in an enclosure to l the application, since the application without the enclosure will also be placed in the Public Document Room. If we do not hear from you in i

this regard within the specified period, the report will be placed in the Public Document Room.

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Houston Lighting and Power P- s> 7/

Company Should you have any questions concerning this investigation, we will be pleased to discuss them with you.

Sincerely.

Original 3,..,,ca :...

W. C'. S.;..%

W. C. Seidle, Chief Reactor Construction and Engineering Support Branch

Enclosure:

IE InNeett$ghtdonReport Nos. 50-498/78-12 50-499/78-12 bec to Reproduction Unit bec to DA:ADM for distribution .r .>.2. d for distribution f //-pr AD/RCI (Reinmuth) Central Files IE Files PDR Standards Development LPDR ELD TIC NRR(9Cys)2/ NSIC MIPC bec distributed by RIV 9 -e 5 2r Texas Dept. of Health Resources 1

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Report Nos. 50-498/78-12; 50-499/78-12 Docket Nos. 50-498; 50-499 Category A2 Licensee: Houston Lighting and Power Company Post Office Box 1700 Houston, Texas 77001 Facility Name: South Texas Project, Units 1 and 2 Investigation at: South Texas Project, Matagorda County, Texas Investigation conducted: July 25-28, 1978 Investigator: *L-J. 7. Ward, Investigation Specialist 8/MM Date t

Inspectors: N/, .M !b P/MhTf W. G. Hubacek, Reactor Inspector, Projects Date Section W. A. Crossman, Chief, Projects Section Yh/78 Date Approved by: y W. A. Crossman, Chief, Projects Section Date M4'l2'1&{395 LSpp-t

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, , , ,3 Investigation Summary:

Investigation on July 25-28, 1978 (Report No. 50-498/78-12;50-499/78-12)

Areas Inspected: Special, unannounced investigation of allegations of in- ",

sufficient training for implementation of newly issued procedures; inadequate -

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nonconformance reporting system; reluctance by QA to issue nonconformance ,

reports; inadequate support of QC inspectors; poor control of QC documents; inaccurate as-built drawings; inaccessability of upper management; undue pressure on QC inspectors; performance of repairs without approved proce-dures; and inability of construction engineers to perform work. The investigation involved seventy-two inspector-hours on site by three NRC inspectors.

Results: No items of noncompliance or deviations were identified, s ,

4 INTRODUCTION The South Texas Project, Units No. I and 2, are under construction in Matagorda County, Texas near the town of lladsworth Texas. Houston Lighting and Power Company is the Construction Permit holder. Brown and Root, Incorporated is both Architect Engineer and Constructor for the plant.

REASON FOR INVESTIGATION The Region IV Project Inspector for STP received a telephone call from an STP employee who reported cn alleged breakdown in the STP civil QA program.

SUMMARY

OF FACTS On July 19, 1978, the RIV Project Inspector received a telephone call from an individual who identified himself as an employee at the South Texas Project.

The employee wished to report alleged irregularities in the civil QA program at STP. The allegation involved the following concerns in relation to the STP QA program:

1. Inability of civil QC inspectors to do their jobs due to issuance of new i

procedures withouth sufficient training in the new procedures before implementation.

2. An inadequate nonconformance reporting system.

3. QA reluctance to issue nonconformance reports when problems are identified by QC.

4. Inadequate support of QC inspectors by QA.

5. Poor document control for drawings and documents used by craft and QC personnel.

6. Inaccurate Cadweld as-built drawings for the Unit 2 fill slab.

7. Inaccessability of upper management.

8. Undue pressure from construction on QC inspectors.

9. Performance of repairs without approved procedures.

10. Inability of construction engineers to do their jobs in assuring that civil construction was performed in accordance with drawings and procedures.

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CONCLUSIONS

1. The allegation regarding insufficient training of.the civil QC inspectors was not substantiated since it is not possible to assess the amount of .

training required to implement the procedures and the degree of training that was actually provided.

2. The allegation concerning an inadequate nonconformance reporting system was not substantiated by specific example. The conditions described by the QC inspectors suggest that the reporting system has weaknesses.

3. The allegation of QA reluctance to issue nonconformance reports when ,

problems are identified by QC could not be substantiated by specific examples. However, generalizations presented by the.QC inspectors

,) indicate that this situation could exist. , '

4. The allegation of. inadequate support of QC inspectors by the QA engineers was not substantiated by specific example, but the majority of the QC inspectors interviewed stated there was lack of support.

5. Review of the QC document control system and interviews with responsible individuals tends to provide support to the allegation of. poor document control of drawings and documents used by QC personnel. However, no specific examples were provided to actually substantiate the allegation.

6. The allegation concerning inaccurate Cadweld as-built drawings for the

Unit No. 2 fill slab was thoroughly checked out but could not be sub- ,

stantiated. -

7. The allegation of inaccessability to upper raanagement was expressed by i a majority of the QC inspei: tors. ,

8. The allegation concerning undue pressure from construction on QC inspectors '

could be valid considering the extensive numbers of items on the QC in-spector inspection " punch lists."

9. The allegation of performance of repairs without approved procedures was not substantiated. The specific example cited was traced to a FREA which contained appropriate recommended action.

10. Although the allegation regarding the inability of the construction engineers to do their job could not be wholly substantiated, the exten-sive number and types of deficiencies contained in the QC inspection

" punch lists" suggests the possibility that the inspections by the craft supervisors and the engineer is, perhaps, less than adequate.

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.e m DETAILS

1. Persons Contacted Principal Licensee Employees -

S. A. Viaclovsky, Project QA Supervisor, HL8P T. Stanley, QA Supervisor, HL&P Brown & Root, Inc.

Individuals "A" through "N"

2. Investigation July 25-28, 197E

a. Allegation No. 1 Inability of QC inspectors to do their jobs due to issuance of new quality construction procedures without sufficient training in the new procedures before implementation.

Findings Individual "M" stated that he had received no training related to

' the new quality construction procedures prior to their implementa-tion on June 26, 1978. He also stated that the procedures were implemented by delivery of new procedures to QC personnel at 10:30 a.m. on June 26, 1978, followed by immediate recall of the old procedures. Individual "M" further stated that a meeting with construction for the purpose of discussing the new procedures did not address the procedures and that a planned orientation for QC inspectors failed to materialize.

Individuals "B," "C," "D," "F," "G," "H," "I," "J." "K," "L" and "N" were interviewed by RIV representatives and questioned with regard to training that had been provided for QC inspectors. In-dividuals "B," "D," "F," "G," "H" and "I" stated that training related to the new procedures was inadequate and that they had experienced difficulties in following the documentation require-ments contained in the procedures. Individual "N" stated that, although he considered the training to be inadequate, he person-ally had encountered no significant problems with the implementa-tion of the new procedures.

R ,R Individuals "C" and "J" stated that they had been able to review the new procedures prior to implementation and hnd not encountered any significant problems.

Individual "L" stated that he considered the new procedures and the training provided to.be~ adequate. He further stated that no substantive changes were made in the new procedures and that only minimal training was required prior to implemen-tation.

Individual "K" stated that training related to new quality assurance procedures (QAP) was provided for supervisors and lead inspectors on or about June 26, 1978, and training sessions related to quality construction procedures were held by con-struction on June 12,13 and 14,1978, for construction and QC

. personnel . He also stated that training sessions are held once per week by supervisors who select procedures to be covered and determine the priority of training required. Individual "K" further stated that a letter issued by the B&R Project QA Manager required all QA/QC personnel to read the new QAPs by July 7,1978.

The RIV representatives reviewed the new quality construction procedures and documentation of the training provided to con-struction and QA/QC personnel. It was observed that the new set of quality construction procedures integrates requirements previ-

, ously contained in two separate sets of procedures used by the construction and QA/QC departments. The inspection requirements contained _in the new procedures appear to be substantially the same as those contained in the old procedures; however, documen-tation requirements for inspection of concrete preplacement and placement activities have been changed. The format used to docu-ment inspection of concrete placements has been revised and expand-ed from 28 to 64 items. This expansion of inspection items and the new format apparently contributed to the difficulties described by some of the QC inspectors who were interviewed. Training records indicated that some QA/QC and construction personnel had attended training related to the new procedures but the adequacy of the training provided could not be determined.

No items of noncompliance or deviations were identified.

b. Allegation No. 2 The STP QA program does not provide an adequate nonconformance reporting system.

A Findings Individual "L" stated that the old method of reporting deficiencies by Deficiency and Disposition Report (DDR) had been eliminated and a new, single purpose form. Nonconformance Report (NCR), was now being utilized. He also stated- that anyone could identify a defi-ciency, but QA issues the NCR.' He knew of no instance where there was resistance by the QA engineer to issue an NCR.

Individual "D" stated that the NCR procedure ST-QAP-2.6 did not offer specific enough guidance for issuance of NCRs. He presented as an example, the prepour activities covered on the " Concrete Pour Card" of CCP-3, Rev. 8, 5/15/78. He stated that original oral guidance was to report all deficiencies detected by the QC inspectors as NCRs, but so many NCRs resulted from this practice that QC in-spectors were directed to develop " punch lists" of items which did not conform to plans and specifications. As a consequence, he thought it was difficult to know just when he should write an NCR.

Many of the QC inspectors stated that they had encounterad resistance by the QA engineer to process NCRs. Several QC inspectors were of the opinion that the QA engineer was not technically competent to assess deficiencies and he could not give the QC inspectors technical advice concerning proposed NCRs.

i Individuals "F," "G," "I," "M" and "N" made statements regarding NCRs to the effect that, they had written NCRs which were rejected for no reason; the QC inspectors wrote NCRs and were accused of " nit picking";

the QA engineer's interpretation of specifications, codes or standards cancels out the NCR; the QC inspectors' decisions regarding NCRs are overridden by the QA engineer; and there are occasions when QC in-spectors are instructed not to submit NCRs when they point out valid deficiencies.

In regard to seeking technical advice concerning problem areas, the QC inspectors were " warned about going over the supervisor's head."

The NRC inspectors reviewed several of the examples cited in the area of improper treatment of deficiencies. The NRC inspectors could not substantiate, by review of documentation or direct obser-vation, the specific examples presented by the QC inspectors. How-ever, the conditions described by the QC inspectors suggest that the NCR reporting system has weaknesses.

No items of noncompliance or deviations were identified.

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c. Allegation No. 3 QA reluctance to issue nonconformance reports when problens are identified by QC.

Findings .

Individual "M" stated that QC encounters much resistance from QA in processing Nonconformance Reports (NCRs) initiated by QC and that sone draft NCRs were not issued nor was QC given reasons why they were not issued.

Indidivuals "B," "F," "G," "I" and "N" stated that they had know-ledge of the initiation of several potential NCRs that were submitted to QA for processing but were rejected by QA. It was stated that in many cases the reasons for rejection were not communicated to the initiators of the NCRs. It was also stated that there was no feed-back to the initiator on the status of NCRs that were processed.

No objective evidence which would support this allegation could be developed.

No items of noncompliance or deviations were identified.

d. Allegation No. 4 Inadequate support of QC inspectors by the QA engineer.

Findings a

The civil QC inspectors agreed in majority that there was a lack of technical assistance provided by the on-site QA engineer. The QC inspectors had contacted the QA engineer in Houston several times for technical assistance, but had been cautioned against " going over the supervisor's head."

Individual "F" pointed out that the on-site QA engineer was respon-sible for procedure revision which he considered to be poorly written.

As pointed out in the Findings of Allegation No. 2, five QC inspectors stated that they were not receiving proper support from the-QA engineer in regard to NCR reporting.

No itens of noncompliance or deviations were identified.

e. Allegation No. 5 Poor document control for drawings and documents used by craft and QC personnel.

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4 Findings Individual "M" stated that distribution of documents (including FREAs, DCNs, drawings) was frequently delayed.

Individual "A" stated that the.QA library, which issues documents to the QC disciplines, has been behind in issuance and recall of documents. Individual "A" stated that the. delays had been caused by rapid turnover and shortage of trained personnel in the QA library in addition to delays attributed to equipment failure in the site document control center (DCC). Individual "A" also stated that the backlog of documents in the QA library has been eliminated and that distribution is now current.

Individual "D" stated that shortage of experienced personnel in the QA library was the major factor which caused delays in the distri-bution of documents to QC inspectors in the field.

Individual "G" stated that, due to untimely distribution of documents through the QA library, he has gone to construction or the DCC for

' the latest issues of documents that he needed to perform his in-spections.

Individual "I" stated that document control at his duty station is difficult due to adverse conditions which exist at his " gang box"

, which serves as his office in the field.

Individual "L" stated that issuance of documents by the QA -library has not always been timely but the documents are not uncontrolled.

Field inspectors have assisted in distribution of documents.

Review of the QC document control system and interviews by RIV representatives with personnel tended to support this allegation; however, no specific examples were provided to substantiate the allegation.

No items of noncompliance or deviations were identified, i

f. Allegation No. 6 Inaccurate Cadweld as-built drawings for the Unit 2 fill slab.

4 Findings Specifically, it was alleged that four Cadwelds which were installed in the Unit No. 2 fill slab had been duplicated. That is, the identi-p fication number for the four Cadwelds in actuality should have appeared twice for each of the Cadwelds on the as-built drawing FSQ-0049. The

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HRC inspectors reviewed the control copy of FSQ-0049 in the document vault. The allegation could not be substantiated.

Also, Cadweld 27BV819 was purported to be in the fill slab and should appear on the as-built drawing, but it was in the lay-down yard. The NRC inspectors identified the-Cadweld in the lay-down yard, but it did not appear on the as-built drawing. It was observed that this specific Cadweld had been written over on the as-built drawing.

No items of noncompliance or deviations were identified.

g. Allegation No. 7, Inaccessability of upper management.

Findings Individual "M" stated that QC inspectors were denied access to upper management in cases where immediate supervisors were unable to provide adequate resolution of problems identified by the inspectors.

Statements by other QC civil inspectors tended to support this alle-gation; however, no specific examples were provided to substantiate the allegation.

, No items of noncompliance or deviations were identified.

h. Allegation No. 8 There is undue pressure from construction on the QC inspectors.

Findings In regard to the preplacement inspection in accordance with the Concrete Pour Card (see Findings, Allegation No. 2), several of the QC inspectors produced " punch lists" and stated that, in some cases, neither the craft supervisor nor the Senior Discipline Engineer (or his representative) would sign the Concrete Pour Card until the respective Quality Control Inspector had completed his inspection.

The NRC inspectors were provided with a copy of a Concrete Pour Card which had been signed off by the Chief Project Engineer before the responsible QC inspector had signed off. This sequence is contrary to Section 3.4 of CCP-3. However, follow up by the NRC inspectors revealed that the control copy of the Concrete Pour Card contained in the records vault was corrected to show the Chief Project Engineer authorizing the pour after the QC inspector had signed off.

n m Individuals "B," "C," "D," "I," "M" and "N" stated that the burden of all inspection is on the QC inspector. The craft supervisor and construction engineer are not doing proper in-process inspection as evidenced by the large number and types of deficiencies found by the QC inspectors. Also, they stated that the structural and tech-nical problems should have been identified by the engineer prior to the QC inspection. The QC inspectors pointed out that this practice greatly increases the workload placed on them.

. Individual "B" stated that construction criticizes the QC inspectors for finding discrepancies after the construction engineer overlooks them. He said a statement had been made to the QC inspectors by a construction manager that Brown and Root signs the paychecks and implying QC should not hold up construction.

Individual "M" stated that as soon as construction signs off the

" Concrete Pour Card," they expect QC to sign right away. They do not want to allot QC any time for inspection after construction is through with the erection work.

The NRC inspectors reviewed several " punch lists" provided by the QC inspectors. The lists contain an excessive number of items for which corrective action should have been initiated prior to the QC inspection.

No items of noncompliance or deviations were identified.

i. Allegation No. 9 Performance of repairs without approved procedures.

Findings Individual "M" stated that B&R construction frequently works without procedures. He cited a specific example wherein construction was alleged to have attempted to repair misaligned anchor bolts for waste monitor tanks located in the Unit 1 Mechanical Auxiliary Building (MEA) without a repair procedure.

The RIV representatives observed that Field Request for Engineering Action (FREA) No. 1-C-1298, dated July ll, 1978, was issued with regard to the waste monitor tank anchor bolts. The FREA contained a description of the problem and the recommended disposition includ-ing the method of repair.

This allegation was not substantiated.

No items of noncompliance or deviations were identified.

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j. Allegation No. 10 Inability of construction engineers to do their jobs in assuring that civil construction was performed in accordance with drawings and procedures.

Findings Individual "D" stated that construction engineers are not able to keep up with their work because they are severely undermanned. Con-sequently, they rely on QC to complete the whole scope of inspection.

They must do this to keep up with the construction schedule.

Individual "M" stated that the construction engineers are not per-forming in-process inspection. Consequently, this puts an extra burden on the QC inspectors because the QC inspectors must do the in-process inspection and the final acceptance inspection. Usually, there are very many discrepant items. The bulk of the inspection is left to QC because the construction engineer group is under-staffed.

Individual "B" stated that the total inspection reponsibility is being placed on QC because the construction engineers aren't doing their job. He said that it is obvious that the construction engi-neers are not doing in-process inspection because of the large number and magnitude of deficiencies found during the QC inspection.

Further, he stated, that many of the problems found by QC should have been found by the engineers because they are technical problems.

Also, the majority of the FREAs issued result from the QC inspection so it appears as though the construction engineers are not knowledge-able.

Individual "I" stated in regard to the allegation that problems he is finding should have been identified during construction. If you wait until the construction is complete and find the problem during acceptance inspection, time is lost and there is pressure to get the problems corrected.

Individual "C" stated that discrepancies are brought to the attention of the construction engineer. If the discrepancy cannot be resolved, the QC inspector writes an NCR for QA review.

Individual "N" stated that all inspection is left to the QC inspectors.

The NRC inspectors reviewed several " punch lists" which contained items found during the inspections performed by the QC inspectors.

Many of the itens were observed to be of a type which coulu have

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been identified and corrected during the erection process. The NRC inspectors also noted that, at the time of the investigation, forms had been removed from a concrete placement to correct dis-crepancies. The type and magnitude of discrepancies identified suggest the possibility that in-process inspections are inadequate. ,

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No items of noncompliance or ifeviations were identified.

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• • • • • June 4, 1980 Docket No. 50-498 50-499 MEMORANDUM FOR: File THRU: M . C. Seidle, Chief, RC&ES Branch W. A. Crossman, Chief, Projects Section FROM: W. G. Hubacek, Reactor Inspector, Projects S mcion

SUBJECT:

MEETING WITH HL&P MANAGEMENT TO DISCUSS HL&P RESPONSES TO IE INVESTIGATION REPORT 79-19 AND THE RELATED SHOW '

CAUSE ORDER, SOUTH '.'EXAS PROJECT, UNITS 1 & 2, DN 50-498; 50-499 A meeting was held at the Region IV office on May 16, 1980, at the request of HL&P management, to discuss HL&P responses to IE Investigation Report 79-19 and the related Show Cause Order.

The following persons were in attendance:

E. A. Turner, Vice President, Power Plant Construction and Technical l Services, HL&P I D. G. Barker, Project Manager, HL&P R. A. Frazar, QA Manager, HL&P K. V. Seyfrit, Director, RIV W. C. Seidle, Chief, Reactor Construction & Engineering Support Branch, RIV W. E. Vetter, Assistant to the Director, RIV W. A. Crossman, Chief, Projects Section, RIV R. E. Hall, Chief, Engineering Support Section, RIV J. I. Tapia, Reactor Inspector, RIV W. G. Hubacek, Reactor Inspector, RIV The discussion, lead by HL&P, concentrated primarily on proposed HL&P responses to the Show Cause Order (SCO) to determine if the proposed responses would be acceptable to the NRC. It was emphasized that the information presented was tentative and subject to change. The following SCO items were discussed:

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File - DN 50-498; 50-499 June 4, 1980 VA(1)

HL&P expressed desire to use Bechtel as a consultant because of Bechtel's extensive nuclear experience. Pros and cons of selection of Bechtel were discussed. HL&P is also planning to contract with Management Analysis Corporation (MAC) for assistance with the QA program and staffing of key QA positions by MAC personnel. (Mr. Seyfrit requested RIV be provided resumes of the MAC personnel.) HL&P would maintain oversight of the program. .More personnel with experience willRbe provided by HL&P and B&R. Training' courses for top HL&P and B&R executives are planned (RIV invited to attend).

VA(2)

HL&P will assemble a " Blue Ribbon" panel for consultation on soils problem.

Panel members are to include Professor Seed of the University of California, Dr. Castro of Boston, and Woodward-Clyde Consultants.

VA(3)-

HL&P plans to utilize Nutech as a welding consultant. Mr. Seyfrit expressed concern abott Nutech's NDE experience. Joseph Artuso (previously involved at Crystal River) will be utilized as a concrete consultant.

VA(4)

The B&R QA program brochure and video tape will be destroyed. New documents will be developed.

VA(5)

New stop work procedures will be developed to clarify requirements. Training will be provided to QA/QC and construction personnel involved.

VA(6)

B&R has initiated a trend analysis program for FREAs and NCRs. Not enough experience exists yet for valid analysis of results of first trend report.

VA(7)

The Design Change Notice will be the only formal method for design change.

The FREA will be eliminated.

VA(8)

The record system will be reviewed. Retrievability of documents will be improved.

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File - DN 50-498; 50-499 June 4, 1980 VA(9)

The audit system will be revised. New procedures will be developed.

More training will be provided and management will become more involved in resolution of audit findings. Apparent problems are with depth of

, audits, not form. Surveillance group on site will continue to monitor day to day status of work.

VA(10)

FSAR, Section 2.5.4 will be addressed.

In addition, the HL&P representatives stated that they did not plan to contest the Notice of Violation or the Civil Penalty. They anticipated that timely responses will be submitted.

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'y ' , S s vt' 8 9 . . . . + pf May 22, 1980 Docket No. 50-498 50-499 MEMORANDUM FOR: File THRU: ,

W. C. Seidle, Chief, RC&ES Branch FROM: R. E. Hall, Chief, Engineering Support Section

SUBJECT:

MEETING REGARDING MISSING RECORDS - SOUTH TEXAS PROJECT UNITS 1 & 2, DN 50-498; 50-499 On May 19, 1980, I attended a meeting in the San Antonio office of W. C.

McGlothlin, Jr., Attorney, which included the following other persons:

Finis Cowan, Attorney for HL&P L. R. Jacobi, Supervising Engineer, HL&P S. S. Rodgers, Licensing Team Leader, HL&P Lanny Sinkin, Representative for Citizens Concerned About Nuclear Power W. C. McGlothlin, Jr., Attorney Mr. Cowan initiated the meeting by indicating that HL&P was interested in locating original South Texas Project Cadweld inspection records, which were missing from the project records center. Since copies of several of the missing records had been previously obtained from Mr. Sinkin, HL&P was inter-ested in tracing the origin of the records Mr. Sinkin had in his possession as a possible clue to the whereabouts of the remaining missing records. Mr.

Cowan stressed that he could not offer a promise of immunity from subsequent legal action regarding the removal of these records from the site; however, it was not his intent to pursue legal action at that time.

Mr. Sinkin produced a packet of what appeared to be Cadweld inspection and Cadweld location records from the South Texas Project. My inspection of these records confirmed that they appeared to be original site recorde.

Several had the appearance of having been torn from file folders, and having been folded into quarter sheet size. Mr. Jacobi indicated that the records inspected were not all that had been identified by HL&P as being missing.

Mr. Cowan again stressed that HL&P was interested in exploring the avenue by which Mr. Sinkin had obtained these original records as a possible clue to locating the remaining missing records. Mr. Sinkin closed the meeting with his intent to discuss the matter of the remaining missing records with his intervenor group.

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, This meeting was basically between Messrs Cowan and Sinkin, with McGlothin and myself there'as " third parties"; and with Jacobi and Rodgers as technical support to Cowan.

R. E. Hall, Chief Engineering Support Section i cc: K. V. Seyfrit W. A. Crossman W. G. Hubacek 3

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' . '-j ARLINGTON, TEXAS 76012 "N <....+ f July 2, 1980 Docket No. 50-498 50-499 MEMORANDUM FOR: File THRU: W. C. Seidle, Chief, RC&ES Branch FROM: R. E. Hall, Chief Engineering Support Section W. A. Crossman, Chief, Projects Section

SUBJECT:

- TECHNICAL MEETING WITH HOUSTON LIGHTING AND POWER COMPANY AND BROWN AND ROOT REGARDING SHOW CAUSE ITEMS NO. 5, 6, 7, 8 AND 9 - SOUTH TEXAS PROJECT, UNITS 1 & 2, DN 50-498; 50-499

.At_the request of HL&P, a meeting was held in the Region IV office on June 30, 1980, with the following attendees:

Houston Lighting and Power Company J. W. Briskin, Manager, STP Houston Operations R. L. Ulrey, Support QA Manager A. H. Gutterman, Attorney Brown and Root J. L. Hawks, Engineering Project Manager Nuclear Regulatory Commission K. V. Seyfrit, Director (part time)

W. C. Seidle, Chief, RC&ES Branch (parc time)

W. A. Crosaman, Chief, Projects Section R. E. Hall, Chief, Engineering Support Section H. S. Phillips, STP Resident Reactor Inspector This meeting was a continuation of the meeting held on June 17, 1980, during which HL&P and B&R representatives presented their approach to resolution of the Show Cause Order items.

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File - DN 50-498; 50-499 July 2, 1980 Show Cause Item No. 5 - Stop Work Authority The status of revision of the HL&P and B&R site procedures related to Stop Work authority and implementation were discussed; however, since these pro-cedures will require revision to incorporate recently announced and contem-plated organizational changes, copies are not yet available for review. A target date of July 14 has been established to incorporate necessary changes and issue the procedures.

Show Cause Item No. 6 - Trend Analysis Two basic changes in NCR control were identified: (1) routine rework procedures are to be developed which can be referenced for disposition of identified routine nonconformances; and (2) all NCRs will be completed through disposition (no draft or uncompleted NCRs), and the originating inspector will be furnished a copy of the completed NCR. To accommodate nonconformances beyond the scope of the routine rework procedures, a Material Review Board will be established to define NCR disposition. All NCRs (to be redesignated as DRs) will have a fault code and a cause code established. These codes, along with fault codes from Examination Checklist discrepancies, will be computer evaluated and the results made available to the Trend Analysis Group. Corrective Action Requests will then be used to obtain generic corrective action on repetitive problems.

Show Cause Item No. 7 - Design Change Control The FREA will be discontinued; the design change request aspects of the FREA system will be processed using a Design Change Request. All nonconformance aspects of the FREA system will be processed on the DR system. Engineering disposition of DRs will be accommodated with a new formalized system of design change control.

Show Cause Item No. 8 - Record Control Extensive revision to the procedures and practices for processing records into the records storage system were discussed. These include checklist control of data package contents, Quality Engineering review of records, and control of records in storage. The new procedures should be fully operational by September 1, 1980; however, it was stated that all records already in storage would be reviewed for completeness and accuracy. A final records audit is also planned prior to system turnover from construction to operations.

Show Cause Item No. 9 - Audits A schedule for development of new audit matrices for audits, including incor-

! poration of consultants into the audit schedule was discussed.

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File - DN 50-498; 50-499 July 2, 1980 General

1. The HL&P representatives reported that commitment dates contained in their reply to enforcement items in Inspection Report No. 50-498/79-19; 50-499/79-19, Items 4 and 5 had not been met due to questions resulting from review of subcontractor generated procedures. A completion date of July 3, 1980, was agreed to by the NRC representatives.

2. HL&P requested clarification of reporting requirements of 10 CFR 50.55(e) relative to problems identified during implementation of corrective actions directed by the Show Cause Order. The NRC representative agreed to define a position on this matter.

3. The attorney for HL&P discussed the format to be used in response to the Show Cause Order items. A copy of the planned format.is appended.

, A subsequent meeting is planned in Region IV for July 3 to discuss the HL&P actions relative to Show Cause Item No. 1.

R. E. Hall, Chief Engineering Support Section

= #

W. A. Crossman, Chief Projects Section

Attachment:

South Texas Project Format cc: w/att.

K. V. Seyfrit, RIV H. D. Thornburg, RCI R. E. Shewmaker, KCI H. S. Phillips, RRI - STP W. G. Hubacek, RIV

• • .~ m ,

e South Texas Project Format of Response to Order to Show Cause A. Non-technical Response - a general sunmary of the issues involved and the licensee's response in non-technical terms generally will include the following:

1. Background - a description of the procedure in use at the time of the NRC investigation

2. Problems with the old system - a brief discus-sion of the NRC findings expressed in the investigation report and the findings of HL&P and B&R upon review of the situation

3. Description of specific Response to the Order -

Summary description of new procedures, organ-izational changes, or other approaches to correcting the problems

4. Explanation of how the responses described will correct the problems

5. Schedule - description of the implementation schedule, including procedure issuance dates, training sessions, report completion and trial periods for perfecting new procedures B. Technical Response - as attachments to the non-technical response, each response will have one or more of the following, depending on the nature of the order, the progress toward completion on the response date, etc.

1. Draft or Completed Procedures - in some cases the procedures will already be in use at the site, in others the procedures may still be under review within HL&P and B&R.

2. Logic Diagrams - to assist in understanding the way the new procedures will work

3. Interim Reports - results of studies completed as of the response date

4. Detailed Procedure descriptions for more compli-cated procedures, such as the field change system.

5. The New QA Brochure (response to item 4)

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% ..... July 21, 1980 Docket No. 50-498 50-499 pu,WMEMORANDUMFOR:y.C.Seidle, Chie

'RLvW. A. Crossman, Chief, Projects Section FROM: H. S. Phillips, Resident Reactor Inspector, STP

SUBJECT:

SOUTH TEXAS PROJECT INVESTIGATION 79-19 LESSONS LEARNED Past history, including QA history, is only valuable if it leads to an improved present or future condition. Team me;bers stated, after the investigation, that NRC managers, supervisors, inspectors and investi-gators should be made aware of lessons learned from the subject investi-gation which started on November 2, 1979 and ended January 24, 1980.

The following are my observations based on 22 years of QA and technical experience, as well as, the past few years working / observing the NRC inspection system. These comments are constructively offered so that the NRC might improve future investigations and so that the NRC might detect QA program breakdowns at the earliest possible time. Some of the coments are specifically related to the conduct of the investigation while the QA program comments address more generic issues relative to the NRC inspection system.

1. Lessons Learned Relative to OA Proarammatic Breakdown The saying that, "An ounce of prevention is worth a pound of cure" may well apply to the STP South Texas Project QA program partial breakdown.

I believe Region IV did the best they could to identify the problems at South Texas Nuclear Project, but were unable to conclusively show a QA programmatic breakdown because they did not have adequate manpower to perform a lengthy and in depth review. It was a very difficult task efor the investigation team which spent nearly 3 months on site,to identify the problems. The team also spent considerable time off site after the investigation documenting the results. After extensive evaluation of the results, the parts of the puzzle came together to give a clear picture of a partial program breakdown.

It is important for NRC managers to realize that QA programs can only be adequately evaluated by more extensive reviews than have been the practice in the past,

a. Needed Imorovement: The NRC does a fair job of evaluating the licensee's establishment of a QA/QC program during the Pre Const-ruction Permit (PRECP) inspection phase, however, after that the NRC's inspection system shifts it's primary attention to random di fdil

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, 2 inspection of hardware. As a result the licensee's and the con-tractor's QA program / systems, including the quality control func-tion, can fail or partially fail and go undetected because of the emphasis on isolated inspections instead of NRC inspections and an annual in depth QA review / audit to evaluate any trends to detemine if there have been any partial or total QA/QC programatic break-down since the PRE-CP inspections verified QA/QC program establish-ment at the corporate and site level.

It appears that the NRC has not had adequate manpower to routinely perfom these types of reviews and also perform routine and reac-tive inspections required.

• Recommendation: A review of each licensee's corporate and site QA program and systems which implement the eighteen (18) criteria of 10 CFR 50 Appendix B should be perfomed by a special NRC team annually. An in depth review should serve as a basis for recommend-ing that construction work, in whole or part, should continue for another year, that is, until the next QA review. These annual reviews of construction activities should continue until the operating licensee is granted. This would reaffim the PRE CP decision relative to QA program establishment and implementation.

As'suming this recommendation was implemented, it would be necessary to provide additional manpower needed by each region to perform such in depth reviews. Such reviews would require 4-5 inspectors for 4-6 weeks on each construction site. The added manpower would payoff in increasing the probability of the NRC's discovering QA programatic breakdowns early in the project, thus eliminating situations which could lead to potentially serious construction deficiencies or concerns. This greater involvement should give the public greater confidence that all is well throughout the construction phase.

b. Needed Improvement: The NRC placed resident inspectors on sites well after the project started. Therefore, the project has not received the same attention as later in the project. It is a well known fact that good or bad habits are developed early in a project and should be identified early for quickest and easiest resolution by the licensee.

Recommendation: The resident inspector should be assigne'd at the earliest practical time after the construction permit is issued because it-is critical that the NRC assure continued implementation.

! c. Needed Improvement: The NRC currently assigns one resident inspector to a designated site. I don't believe one can do the job that should be done. The following factors appear to have received insufficient consideration in determining manpower:

(1) The construction phase is probably more complex than the operations phase since the resident has to deal with several

. different site organizations with 3000-4000 workers which include top managers and workers in licensing, quality assurance, engineer-ing, and construction. Usually there are several different QA programs on site i.e. licensee, and contractors who are responsible for their respective QA/QC effort, (2) Reactive inspection effort can te quite extensive because of 50.55(e) deficiences, allegations,

.o . 3 and interviews and will take a considerable amount of the resident's time. News media interest is also a factor, (3) Licensee / contractor performance can require more or less of the resident inspector's  :

time depending on the frequency and/or seriousness of problems, (4) Quality and reliability must be built into a plant making the construction phase very important. A plant will realfably operate only as well as it is constructed. Several other considerations could be stated but these are a few examples which sould make a point. It would be more appropriate to discuss such subjects-in a manpower justification report should NRC management choose to do so.

Recomendation: The NRC should consider assigning additional engineering / inspection personnel to the site to do a more adequate job. As a minimum, a second inspector should be added to multi unit sites when construction of the first unit is 30-40% completed.

I have worked in other government agencies / projects and can safely say that their minimum QA staffing of a project such as this would consist of one senior resident inspector, a discipline engineer for each discipline (civil, mechanical, electrical) and a QA spec-ialist/QC inspector for each discipline. In the case of poor licensee / contractor performance perhaps double this number would be' assigned.

Several options exist relative to additional manpower.

(1) Permanent inspectors could be hired at the GS-11 and GS-12 level and work to higher grades. (2) Highly competent and highly compensated temporary inspectors could be hired with the same understanding of most construction workers, that is, when the project ends the individual would have to find other work if a permanent position were not available.

2. Lessons Learned on Conducting Extensive Investigations

a. Needed Improvement: Some members of the inspection team lacked the desired NRC experience to participate in such an extensive investigation / inspection.

Recomendation: Each team member should have no less than one year NRC experience when participating in a special investiga-tion / inspection. Technical expertise not available on the team should be supplemented. For example, technical experts with less experience could participate as needed but should be assigned to a senior team member who would be responsible for directing the effort. Such technical experts would submit findings to the senior team member who would be responsible for including the finding in the final report.

b. Needed Improvement: A great number of interviews were conducted during the investigation and, as a result, the last half of the 50 persons to be interviewed appeared to know the line of questioning. In other instances, a few of the interviewees appeared to be under intense pressure because they were the last to be interviewed. That is, they waited so long to be interviewed that they tried to read something into being last, a

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r 4 L Recommended: -Identify this as a potential problem before a lengthy interview process begins or early into the interview process. Furnish two investigators and assign a technical

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person for each to shorten the interview time if the interview process is to be lengthy, i.e. more than two weeks.

c. Needed Improvement: I participated on the team as the Region IV representative but reported to the team leader from another region during this period of time. I was given the task to be an objective team member reporting to a team leader from another region. During the investigation I maintained contact with my Regional Supervisor. I kept my supervisors informed as well as I could; however, I did not speak for the team.

Communication rules were not apparent. This was an awkward situation.

Recommendation: My first inclination would be to recommend that the Regional Project, resident or engineering inspectors, not be a part of the team, however, in the case of the resident /

project inspector this must be weighed against the advantage of having their broad knowledge and feel for the project and per-sonnel. If a Regional inspector is assigned to the team, Headquarters, Region Management, and the Team Leader should establish rules of communication during the investigation that will keep Region fianagement informed. This would have improved the situation whether Region IV personnel participated or not.

d. Needed Improvement: The team held briefings with the licensee intermittedly and there was a management meeting at the midpoint of the three month inspection. Some of the team's findings were not fully developed, however, preliminary findings were discussed with the licensee. As a result, the licensee began to take cor-rective action on the basis of these discussions and began dealing with Region IV, the Resident Inspector, and the Team Leader regard-ing tentative and final findings before the inspection was com-pleted. This caused several potential problems: (1) an official corrective action response to a briefing was made four months before the licensee received the official report, (2) reacting ,

to findings before evaluations were completed could have led to incorrect corrective action, (3) potential compromise of NRC enforcement was real and, (4) feedback of information to the per-sonnel yet to be interviewed may have caused the interview pro-cess to be less effective.

Recommendation: Only a final exit interview should be conducted during an investigation; however, activities in progress, such as pouring concrete in an unsatisfactory manner, which makes correction difficult if not impossible would be reason to identify

.. such problems to the licensee during the investigation / inspection.

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e. Needed Improvement: The Investigation Report 498;499/79-19 which documented investigation and inspection results was a large work effort which took several weeks to put together after the investigation / inspection effort ended on January 24, 1980. Then each participant went back to their respective work locations in different regions where they drafted their part of the report without the benefit of direction. That is, closer direction would have been beneficial relative to uniform format, style and content. Also, coordination was not possible relative to notes taken by both NRC personnel conducting the interviews. 1 Inspectors who worked in the same areas or who identified similar l nonconformances that constituted trends were also unable to coordinate without writing this initial draft. As a result, after the first draft was submitted, it was apparent that the team would have to reassemble to get the job done.

Prior to the Team's reassembling to Headquarters, a preliminary write up of the proposed Appendix "A", Notice of Violation, was furnished to Region IV Construction Branch for comment without the benefit of the report details to support the pro-posed Notit.e of Violation. Solicited comments without full documentation of findings led to less than satisfactory comments being furnished back to the team. Starting off on the wrong foot may have given the impression that the team could not document the noncompliances. The comments may have given team members the impression that those commenting did not understand the full significance of the team findings.

Recommendation: In retrospect, the team should have remained intact immediately following the exit until the first draft was completed. A draft of the Notice of Violation should not have been furnished for comment without a draft of report details.

The craft Notice of Violation could have been submitted without a draft of the details for information only.

i g H. S. Phillips, Resident Reactor Inspector, STP